ON JUNE 24, 2009, EPA ISSUED A NOTICE OF DETERMINATION ( NOD ) PURSUANT TO THE FINAL POLICY STATEMENT ON INCENTIVES FOR SELF-POLICING: DISCOVERY, DISCLOSURE, CORRECTION, AND PREVENTION OF VIOLATIONS, 65 FED. REG. 19618 (APRIL 11, 2000). THE NOD IS BASED ON A SELF-DISCLOSURE PROVIDED BY NTN-BCA CORPORATION ( NTN-BCA ) FOR VIOLATIONS OF SECTION 312 OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ( EPCRA ) 42 U.S.C. SECTION 11022, AND ITS IMPLEMENTING REGULATIONS AT 40 C.F.R. PART 370. NTN-BCA DISCLOSED THAT THE FACILITY HAD FAILED TO SUBMITT A TIER II REPORT TO THE LEPC, SERC, AND THE LOCAL FIRE DEPARTMENT FOR PETROLEUM BASED CHEMICALS STORED IN QUANTITIES THAT EXCEEDED THE 10,000 POUND MINIMUM THRESHOLD AT THE FACILITY DURING CALENDAR YEAR 2007, IN VIOLATION OF EPCRA SECTION 312.